The Commission proposes the automatic exchange of data on the beneficial owners of real estate properties in other EU member states

EU tax administrations would automatically receive information about the beneficial owners of real estate properties owned by their residents in other Member States, not just the available data on the formal owner and income earned from real estate. The reform of the Directive on administrative cooperation in the field of taxation would give tax authorities direct access to information from real estate and beneficial ownership registers. The mechanism does not introduce a European wealth tax and does not turn this data into a public register.

Tax administrations in the European Union would also exchange automatically information about the beneficial owners of real estate properties, expanding a system that already allows data on taxpayers’ real estate ownership and income to be transmitted between states. The change appears in the reform of the Directive on administrative cooperation in the field of taxation, DAC, while the Commission also wants tax authorities to be able to access information held in other national administration registers, even if it is not currently found in their own databases.

In brief

Proposal COM(2026) 308 explicitly adds the beneficial owner to information on real estate ownership that can be exchanged automatically between the tax administrations of EU states.

The available information would no longer be limited to tax authority databases. Tax authorities could also use registers and databases administered by other national authorities.

For real estate, tax authorities would receive direct access to the national access point provided for under EU anti-money-laundering legislation, including information about individuals, companies and legal arrangements that own the properties.

The data exchange does not create a European wealth tax and does not determine how much tax the owner must pay. Taxation remains determined by national legislation and by the rules applicable to the situation concerned.

In the form proposed by the Commission, the changes concerning properties and beneficial owners should be transposed by 31 December 2029 and applied from 1 January 2030. However, the text must first be adopted by the Council, after consultation with the European Parliament.

Member States already exchange tax information on real estate ownership and income derived from property, but the current system has an important practical limitation. The DAC Directive requires a state’s administration to transmit “available” data about a resident of another state, and this notion has largely been linked to information actually held in the tax administration’s files and databases. If data about a property exist in a land register administered by another authority, they do not necessarily automatically enter the European tax information exchange system.

The Commission’s assessment shows the scale of this difference: 24 of the 27 Member States currently exchange information in the category of real estate ownership and income, while other categories are covered by a different number of administrations. The reform seeks to turn information already held by the state into a resource also available for tax cooperation, without requiring the taxpayer to provide the same data again to another institution.

Under the new definition, “available information” would include data held in public administration registers and databases at national level, not only what is already in tax authority systems. For properties, the Commission links this change to the infrastructure created by the new European anti-money-laundering rules, which require states to organize electronic access to information about real estate assets, their owners and relevant transactions.

The proposal goes beyond identifying the name entered in a property register. The article on the automatic exchange of information explicitly also includes “beneficial ownership”, the beneficial owner of the property. Where ownership is held through a company, trust or another legal arrangement, the tax administration could thus also access information about the person who ultimately stands behind the ownership structure, in accordance with the definitions used by European anti-money-laundering legislation.

This difference can be significant in the case of cross-border assets. A property register may indicate a company as the legal owner of an apartment, building or plot of land, while information about the beneficial owner identifies the person or persons who ultimately own or control that company or structure. Combining the two types of data makes it easier for the tax administration to link the asset to the taxpayer in its own jurisdiction.

For a Romanian tax resident, the mechanism could mean that information available in another Member State about a property they own directly or of which they are the beneficial owner may be transmitted to the Romanian tax administration. Conversely, the Romanian authorities could provide the tax administration of another state with available information about properties in Romania linked to residents of that state.

The transmission of information does not, however, determine whether a tax obligation arises or its amount. The place where income must be declared, the treatment of a property and any obligations concerning income tax, capital gains, wealth or other taxes continue to depend on national legislation and, where applicable, double-taxation treaties. The DAC organizes cooperation between administrations; it does not introduce a European tax on property.

This distinction is relevant in the context of the fact that the dossier was discussed at the same parliamentary meeting in which Members of the European Parliament and national parliamentarians separately debated the possibility of taxing individuals with very large fortunes. The automatic exchange of information about properties and their beneficial owners is a specific legislative proposal concerning administrations’ ability to identify cross-border assets. The debate on a possible tax on large fortunes is a separate political dossier, and no such tax is created by the DAC reform.

The Commission also proposes changing how tax administrations actually access information. States should provide them with immediate, direct and free access to data enabling the identification of a property and the individuals, legal entities or structures that own it, as well as relevant information about transactions. Access would be provided electronically through a single point in each state, and the data should be available in digital format and, where possible, in a form that can be processed automatically.

The same system does not become accessible to the public through this reform. The proposal concerns competent tax authorities and administrative exchanges between states, while the use of data remains subject to European data-protection rules. The Commission provides that exchanges will take place through secure electronic infrastructure and that access within tax administrations will be restricted to authorized officials.

For the category covering real estate, the information should be transmitted at least annually, as soon as possible after it becomes available and, in any event, within the period established by the directive after the end of the relevant tax year. The system is designed so that the administration in the state of residence can compare information received from abroad with the tax returns and tax data it already holds.

The reform also addresses another problem identified by the Commission: states do not currently exchange all the same categories of information. After removing the separate category concerning certain life-insurance products, which the Commission considers largely redundant with other reporting obligations, six main categories would remain. The proposal requires all of them to be included in the automatic exchange whenever the information is available, replacing a system in which coverage differs from one state to another.

The extension to beneficial owners of real estate also follows OECD work on the exchange of tax information about properties. The international standard developed in 2025 aims to enable tax administrations to use information already available in national registers to see beyond the formal owner and identify cross-border ownership structures.

The Commission presented its proposal to reform the DAC on 24 June. The dossier, registered as 2026/0168(CNS), is under the consultation procedure, with the European Parliament’s Committee on Economic and Monetary Affairs responsible for Parliament’s position. The Council is the institution that must adopt the directive, and in tax matters the decision requires the unanimous agreement of the Member States.

The timetable in the Commission proposal places the application of the main changes concerning real estate information on 1 January 2030, following national transposition by the end of 2029. These dates form part of the legislative proposal and may change during negotiations between the states before the final form is adopted.

https://2eu.brussels/ro/news/comisia-propune-schimb-automat-de-date-despre-beneficiarii-reali-ai-proprietatilor-imobiliare-din-alte-state-ue